Last Updated: August 2nd, 2026

The following information contains First Liberties Financial's Privacy Policy designed to protect the confidentiality of current or former customers ("you") of First Liberties Financial.

First Liberties Financial has established a relationship with you as a result of your opening a brokerage account with First Liberties Financial, a licensed broker/dealer, or with a licensed broker/dealer that utilizes First Liberties Financial to effect securities transactions for your account or perform other brokerage services. This means we receive your nonpublic personal information for the sole purpose of servicing your account.

This information is presented to you in conformity with 15 U.S.C. 6801-6810 and the Securities and Exchange Act of 1934 as amended by 15 U.S.C. 6801-6810. The nonpublic personal information, which identifies you or your account, is hereafter referred to as "personal information".

Maintaining personal information securely and confidentially is a First Liberties Financial priority. The following information will explain our privacy policy in more detail.

YOUR NONPUBLIC PERSONAL INFORMATION

FIRST LIBERTIES FINANCIAL DOES NOT SELL YOUR NONPUBLIC PERSONAL INFORMATION. WE WILL ONLY DISCLOSE YOUR NONPUBLIC PERSONAL INFORMATION, WHICH INCLUDES ANY PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU, AS INDICATED IN THIS POLICY, IF WE HAVE OBTAINED YOUR CONSENT OR WE ARE REQUIRED BY LAW TO DISCLOSE SUCH INFORMATION.

NONPUBLIC PERSONAL INFORMATION COLLECTED

In order to provide you with the highest quality of service, First Liberties Financial collects the following types of nonpublic personal information:

A. Information from you.

Information you provide on an application for an account, a loan, debit card or any other financial product or service, whether in writing, in person, by telephone, electronically or by any other means, such as your name, address, social security number, assets, income, and debt; and

Information we obtain for the purpose of tax reporting to you and to the various agencies to which we report as required by law, including disclosures on various Internal Revenue Service (IRS) forms that we collect for tax reporting purposes.

B. Information about your transactions with us.

Information that relates to account balance, payment history, trading activity and any other such transactions for which First Liberties Financial provides brokerage services;

Information we collect as part of authentication for purposes of servicing your account in a secure and confidential fashion; and

Information we collect through an Internet "cookie" (an information collecting device from a web server).

C. Information about your transactions with nonaffiliated third parties.

Information provided to other nonaffiliated third parties as required by law, including information shared in connection with a subpoena or other legal document compelling our compliance; and

Information provided to financial institutions with which we have a joint marketing agreement.

D. Information from a consumer-reporting agency.

Information from a consumer reporting agency regarding your creditworthiness or credit history or other information with regards to lending;

Information about the fact that you are a customer of First Liberties Financial and we have provided you a financial product or service; and

Information from other outside sources regarding their employment of, credit to, or other relationship with you, or verifying representations made by you, such as your employment history, loan or credit card balances.

NONPUBLIC PERSONAL INFORMATION DISCLOSED

In the ordinary course of providing financial services for your account, nonpublic personal information is disclosed to nonaffiliated third parties as required by law or with your authorization. In addition, we may disclose the information we collect to financial institutions with whom we have a joint marketing agreement.

AFFILIATES AND NONAFFILIATED THIRD PARTIES TO WHOM WE DISCLOSE

First Liberties Financial has several affiliated companies, including Pelion Investment Advisors, Inc. The sharing of your information among our affiliates enables us to serve you more efficiently and makes it more convenient for you to do business with us. We only share your information with our affiliates when an agreement between you and our affiliate is in place and then only when it serves to benefit you. First Liberties Financial does not disclose any nonpublic personal information about you except as permitted by law or with your authorization.

FORMER CUSTOMERS

First Liberties Financial will only disclose nonpublic personal information about former customers as required by law or with their authorization.

PRIORITIZING SECURITY OF INFORMATION

First Liberties Financial is committed to maintaining appropriate measures to insure that your information is secure and confidential. First Liberties Financial information and security procedures include, but are not limited to, the following features:

Access controls on customer information systems, including controls to authenticate and permit access only to authorized individuals and controls to prevent employees from providing customer information to unauthorized individuals who may seek to obtain this information through fraudulent means.

Physical access restrictions at locations containing customer information, such as buildings, computer facilities, and record storage facilities to restrict access to unauthorized individuals.

Encryption of electronic customer information where appropriate.

Stringent pre-employment screening, including fingerprinting, and segregation of duties for employees with responsibilities for or access to customer information.

Monitoring systems and procedures to detect actual and attempted attacks on or intrusions into customer information systems.

Response programs that specify actions to be taken when First Liberties Financial suspects or detects that unauthorized individuals may have gained access to customer information systems.

A disaster recovery plan to protect against loss of or damage to customer information due to potential environmental hazards, such as fire and water damage or technological.

First Liberties Financial regularly revises and updates its information security program to keep pace with changes in technology.

First Liberties Financial is a member of the Financial Industry Regulatory Authority, the Municipal Securities Rulemaking Board, and the Securities Investor Protection Corporation.

SMS TEXT MESSAGING

If you provide your phone number and consent to receive SMS messages from us, the following terms apply:

You may receive SMS messages related to consultation scheduling, follow-ups, and updates about our services.

Message frequency will vary based on your interactions with us.

Message and data rates may apply depending on your mobile carrier and plan.

To opt out of SMS messages at any time, reply STOP to any message we send you.

To request assistance, reply HELP to any message, or contact us using the information on our Contact page

We do not sell or share your phone number with third parties for their marketing purposes.

Carriers are not liable for delayed or undelivered messages.

THIRD-PARTY LINKS

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies independently.

CHILDREN'S PRIVACY

Our services are not directed to individuals under 18. We do not knowingly collect personal information from minors.

CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. Changes will be posted on this page with a revised "Last Updated" date. We encourage you to review this policy regularly.

CONTACT US

If you have questions or concerns about this Privacy Policy or our data practices, please visit our Contact page at www.firstlibertiesfinancial.com/contact